The group has heard that EIOPA is willing to launch a survey on commercial tools for undertakings, as decided in the ITDC; the survey is probably being similar to the Eurofiling one (http://eurofiling.info/portal/xbrl-solutions/).

EBA taxonomy version 2.4.1 is about to be updated with small tweeks to a few validation rules – instance compatible
This version is to be used for three months (Sep-Oct-Nov)
EBA version 2.5.0 will similarly be updated soon with equally a few minor tweeks to validation rules – instance compatible

The group discusses experiences with national differences in the actual adoption of a new taxonomy version (or fix) because the decision to deploy any taxonomy is a national one.
In some countries it may occur that assertions are or are not deactivated in the same way as in EBA’s official validation rules list.

This topic will be discussed during the Frankfurt days.2) ECB

Discussion on AnaCredit.
At this moment, ECB has not (yet) proposed a pan-European technical standard to collect AnaCredit data.
It needs to be said that the collection channel (European System of Central Banks) is different from the one we are used to (Supervision) for COREP and FINREP data.
Therefore, the top-down approach is different.
The group discusses the observations so far:
- ECB has not taken a decision on the standardisation of this topic
- Meanwhile, ECB is being influenced by individual parties to choose another path away from XBRL
- AnaCredit is aiming to collect data volumes which are larger than the ones we are used to.
- XBRL as a standard has already solved the large volume” challenge in different ways. In the world, several data collection systems exist with XBRL and with large data volumes: size doesn’t matter.
- The question is more: what level of upfront validation and openness hereof does ECB want to reinforce? Data can be sourced in many ways.
- XBRL as a standard is solving a lot of the traditional garbage-in-garbage-out challenge.
- XBRL opens in a standard way to all stakeholders involved the validation rules applied.
- It may also be worthwhile to look at overlapping data definitions and cross-checks with existing EBA (and EIOPA?) taxonomies. The business case to converge to one standard to reduce burden for reporting institutions could emerge in such a case.
- “The use of enumerations reduces the size of instance documents”.
- Is there an implication on ISO2022?

The group suggests to discuss this in Frankfurt and involve XII in the discussion.

3) EIOPA

EIOPA will deactivate 8 more assertions in v2.0.1 in the next period.

Draft taxonomy 2.1.0 will be released during the XBRL week in Frankfurt.

This taxonomy will use the assertion severity specification which is newly released by XII, this is to facilitate plausibility checks and trigger ‘warnings’.

Vendors should prepare the implementation of the assertion severity specification.

EIOPA has announced to provide maximum one corrective release per year and one adaptive release per year.

The group elaborates on T4U as a distortion of the solutions market.

Altough EIOPA is expressing intentions to “want to stop the development and support of T4U”, small parties and consulting companies are pressing for continued support as they wish to continue to avail themselves of free software and support.

The group argues that this situation distorts the market for commercial solutions: “free software paid by the European tax payer” rather than “an open source development”. This empedes the working of the open market to develop competitive solutions.

All parties in the group have experienced the loss of opportunities due to the availability of the free T4U software.
The major beneficiaries are consulting companies who are able to sell services around free software and therefore have a competitive advantage.

From a technical perspective, the published version of the open source code is missing a vital part which makes the open source version only usable for the current taxonomy and not the future ones. The missing part is only available to an inner circle.

Hence, few people from the group have expressed the desire to participate to EIOPA’s T4U meet the market event.

However, EIOPA’s wish to decommission T4U can be reinforced by the awareness of the existing market solutions.

Therefore, Eurofiling proposes to generate a factual assessment of commercially available software by creating a list of companies that “offer solutions to deal with Solvency II and XBRL”
It is hoped that this list will demonstrate to EIOPA the real nature of the solutions (still) in the market today and restore the balance.

4) National Specific Templates

The group noted that a number of NCAs are using XBRL to collect additional local data

The approaches adopted are not coordinated and do not necessarily follow EBA or EIOPA architectures

Countries include – France, Belgium and Ireland

5) XBRL week in Frankfurt

Explanation on the different days during the XBRL week in Frankfurt. 5 days of meetings.

1) EBA update
2.4.1 is to be used as from September
2.4 is not going to be used because it was incomplete

It’s unclear what NCA’s will do : some seem to wait for a publication in the OJ. The decision to move to 2.4.1 is a national one.

2.4.1 is a patch release on mostly validation rules.

2.5 taxonomy will probably go in production in December.

Roadmap: IFRS9 is foreseen for first quarter of 2018, probably incorporated in 2.7 or later

2) ECB

FINREP IND will for 2016-06 be based on the taxonomy in the 2.3.2 package

3) EIOPA update

Taxonomy update:
An error occurs in the 2.0.1 taxonomy with missing ECB validation rules.
EIOPA is not providing a taxonomy fix, but it has updated the free software T4U.

This is bad news for all tool vendors who not only have to compete against a free software made by the Authority but also now can’t compete because they can’t update their tools to the latest version without using the T4U themselves…

Comments by the working group on Tool4U:
- the open source code published by EIOPA on github is only usable for taxonomy 2.0.1 and not for new taxonomies hereafter
- some of the code is not open source and is only available to the developers of the code
- without this piece of code the open source version of Tool4U cannot be used by other developers after version 2.0.1
- xbrl tool vendors hope that EIOPA will leave the market do its work without providing competitive advantages to the developers of the Tool4U code.

4) XBRL week in Frankfurt (http://www.xbrleurope.org/component/content/article/78-latest-news/140-xbrl-week-in-frankfurt-2016)
Explanation on the different days during the XBRL week in Frankfurt.
Don’t forget to register via the link (https://eurofiling.typeform.com/to/wZeSWy)

The 2.4 taxonomy will not be used before end of May 2016
The group discusses the European implementations of CRDIV : each country has taken measures to deal with level 1 reporting.
Eg. Spain has an elaborated series of DPM based taxonomies.

Eurofiling has a page with the results of an EBA survey on http://www.eurofiling.info/corepTaxonomy/corep_taxonomy_in_europe.shtml

2) EIOPA

EIOPA is also going to start using a calendar such as EBA. For S2_2.0.1, the first remittance date is 20.05.2016.
EIOPA plans to have one corrective version per year and one adaptive version at the end of a year
We can expect the next release around Feb/March 2016

Technical issues with 2.0.1:
Julien has spotted problems with assertions linking to the balance sheet / assets: assertions with nilled typed dimensions have problems. Julien has communicated an alternative solution to EIOPA.
A quickfix could be that EIOPA alters the filing rule which states that you have to put ‘nil’ into ‘NA’, then the problem will not occur.
Julien also detected that validation performance degrades as soon as the number of facts increase, due to large numbers of xpath queries.

T4U is not yet able to work with the 2.0.1 taxonomy. EIOPA will probably release the tool next year, apparently for the last time.

Daniel asks about moderately/highly dimensional. From a data collection point of view, the taxonomy is moderately dimensional but has many dimensions. The taxonomy also holds a highly dimensional section for documentation purposes.

3) ECB

In September, EIOPA released ECB add-ons for reporting to insurance supervisors. Daniel asks if the alignment is also existing for the Banking Sector. The group discusses the fact that for the banking sector, with euro-zone and non-euro zone, the data collection domains are vast and more complex, and has different legacies which will probably take a while before getting harmonised (if ever).
Having said this, ECB has announced during the S2 conference in Paris that ECB considers harmonising nontheless some parts and that XBRL is being looked at.

ECB is doing additional checks (plausibility checks / non blocking rules) which are not officially available, not in any taxonomy nor any other official formal way. Some NCA’s in the Euro zone have shared an Excel overview with their filing institutions.

Next call is 28.01.2016 unless something new happens which urges a talk session.

1) EIOPA has published its official taxonomy (release 2.0.1) on the scheduled date of 21.10.2015
- This version is the official production release, to be used at least for the first quarters.
- EIOPA may start working on an updated taxonomy which could be released during 2016

2) Market uncertainty around the Tool for Undertakings.
- as communicated earlier by EIOPA, the T4U will be phased out by EIOPA after the first reportings. It is expected that this tool will no longer support future versions of the Solvency II taxonomy.
- this is considered as a good thing by the working group and market stakeholders because:
european tax payers should not pay for software edited by a regulator
the market can play its role in providing quality solutions and
market participants do not have to compete against a competitor who is playing in a whole different league

- earlier mentionings of test instances. In the Madrid workshop, it was mentioned that test instances would be made available which either respect or violate certain Filing Rules. So far, these testfiles were not seen in the publications, the group wonders whether such instance documents are foreseen.

3) EBA taxonomy 2.4
- this taxonomy was released in the summer but still has not the legal publication base by the EU available, which means that this taxonomy will not go live for at least the next 6 months.
- meanwhile EBA is working on version 2.5 which will have some enhancements:
adopting the official table linkbase spec (info)
adopting the enumerations specification
etc.
- in the remote background, EBA is also gradually elaborating version 2.6 which will a.o. digest the impacts of IFRS9, which was also mentioned in a presentation from EBA in the Madrid workshop.

4) ESMA consultation on XBRL
- one of the questions is related to the IFRS taxonomy. What is the opinion of the working group?
- the group points out that the EBA FINREP IFRS framework has no link whatsoever to the IFRS taxonomy (anymore), with as main reason that the IFRS taxonomy was too generic for the specific needs for prudential supervision of the banks.
- if ESMA wishes to employ the IFRS taxonomy for listed companies, there will be somewhat reconciliation work XBRL-XBRL for listed banks (and insurers), which will also be the case in any other form of reporting. Prudential reporting is anyways separate from Investors communication

5) CEN: European Filing Rules II
The group considers it a good idea to invite stakeholders to a new workshop.More info

6) Next Eurofiling workshop in Frankfurt
Proposition will be sent to Eurofiling Coordinator to re-issue another survey mid 2016 about 1 or 2 eurofiling conferences per year.

Each new version of a taxonomy, such as corep_2.2.0, contains all artifacts from the previous versions, even if they did not change.
eg. if version A_II has only one change in table 123, then with the current approach, the new taxonomy contains a full copy of all tables 1-122, which unnecessarily doubles the size of the full taxonomy.

>> The working group recommends EBA to rework in the near future the taxonomies to one synchronised taxonomy where only changed files are stored in new taxonomy versions.
2) Publication of taxonomy 2.4
The actual go-live date of this taxonomy is unclear at this point.
It’s a good thing that EBA has put “expected reference date” on the Roadmap !!

3) EBA filing rules
Some member states already start enforcing (or facilitating) filing rules such as the working of the filing indicators.
In 2.4 is specified “not before 2014-12″

4) publication of a draft of the EIOPA full S2 taxonomy is expected in the next week (around 30.09)

1) EBA’s intention to switch to the Table Linkbase REC
The group discusses the paper and is very happy with this news.

2) EIOPA taxonomy 1.7
Most members did not dedicate (a lot of) time to version 1.7.0 and are looking forward to version 2.0 and the assertions. The fact that interval arithmetics may or may not be used is a matter of EIOPA, as long as the thresholds are not becoming a matter of national discretion. The solution must remain European and not create more room for deviation.
Julien has looked at the taxonomy, and considers the rearrangement of templates by EIOPA a good evolution.
Deactivation of rules: the group considers that from a release management point of view, it technically impossible to deal with frequent changes on country-by-country level ! Better to accumulate over longer periods, such as two months.

3) EBA 2.3.1
- being put in production
- table 46 seems to have changed; David gathers input for this potential issue
- Vincent expects EBA to publish its taxonomy 2.4, the date is not known for sure however

4) AOB
Multi-currency: both EBA and EIOPA will adopt the same method, with the proper and intended use of the unitRef and dimensions to take care of “reported in original currency” or “reported in converted currency”

The group discusses in detail the paper, and identifies two scenarios instead of one as proposed in EBA’s paper:

Clean scenario : amounts are expressed using the unitRef to differentiate one from the other

Caveats:
° validation rules would need to take into consideration the unitref to differentiate while evaluating
° this scenario works with fact values from dynamic lists where the primary key is not the currency but an identifier such as Portfolio number
° what if amounts are expressed in both the original currency and a converted value in the reporting currency? What with conversion rates?

- our replies to EIOPA have resulted in the changing of the Filing Rules document, which demonstrates that

- the group thinks that it’s good to have this communication channel to regulators to raise timely issues to regulatory requirements

3) EBA’s whitepaper on multi-currency reporting

After explanation of the intention of the paper, the participants will discuss this further internally and the group agrees to have the final word during the May call, right before the Madrid week.

It is observed that banks are going to need new Software releases to accommodate the definitive multi-currency solution … lots of changes.

4) Madrid : the group recommendation to have a roundtable slot during the Eurofiling day to discuss some of the topics has been honoured with a slot on Wednesday afternoon. The roundtable will include already David Bell, Corefiling and maybe one from Invoke.